Carbon Footprint: What to Enter

The EU Battery Regulation requires every in-scope battery passport to declare the battery's lifecycle carbon footprint. This article explains what the declaration requires, what EU Digital Passport Processor™ collects, where the data comes from, the per-lifecycle-stage breakdown, and how the performance class works.

What the regulation requires

Article 7 of the Battery Regulation (2023/1542), as implemented by Commission Regulation EU 2024/1257, requires a carbon footprint declaration per battery model per manufacturing plant. The declaration must state:

• The declared total carbon footprint value (kg CO₂e/kWh).
• The carbon footprint for each lifecycle stage, where data is available (Article 7(1)(e) and Annex II point 4).
• The lifecycle stages included in the assessment.
• The methodology used.
• The performance class (A–D).
• The name of the notified body that verified the declaration.
• The verification certificate reference number.
• The date of the declaration.

The declaration must be publicly accessible — it is published on the EU Digital Passport Processor™ public viewer alongside the other passport fields.

Mandatory dates by category:

For LMT passports, the carbon footprint declaration fields show an amber Required from 18 Aug 2028 tag. You can fill them in now if you have the data, but they are not required to activate the passport before that date.

What EU Digital Passport Processor™ collects vs what you must obtain externally

EU Digital Passport Processor™ collects, stores, and publishes your declaration. It does not perform the lifecycle assessment (LCA) calculation — that is the responsibility of your LCA consultant working under the JRC Battery Carbon Footprint Boundary methodology.

Before completing the Carbon Footprint Declaration section on your passport, you will need:

1. A completed LCA study from a qualified consultant, following the JRC Battery Carbon Footprint Boundary methodology as defined in Commission Regulation EU 2024/1257.
2. A verification certificate from a notified body authorised under Article 7(3). Notified bodies are listed on the NANDO database (ec.europa.eu/growth/tools-databases/nando).
3. Your performance class (A–D), as determined by the verification body based on your verified declared value.

Where the data comes from

The carbon footprint value must be derived from an LCA conducted using the JRC methodology. The methodology specifies:

• System boundaries (what lifecycle stages to include).
• Data sources (primary data from your production vs secondary data from databases).
• Allocation rules (how shared processes are attributed).
• Impact assessment method (the CO₂e conversion factors).

Most manufacturers commission a specialist LCA consultancy to conduct the study and produce the verified figure. The verified figure is then submitted to a notified body for verification. The notified body issues a certificate.

What to enter in EU Digital Passport Processor™

The Carbon Footprint Declaration section is on the passport detail page (not in the creation wizard — it requires data you will typically receive after the passport is initially created). You can save the declaration fields at any point and activate when all required fields are complete.

Declared carbon footprint (kg CO₂e/kWh) — Carbon Footprint Intensity

The lifecycle carbon footprint expressed as an intensity per unit of energy stored, not as an absolute total. The unit is kg CO₂e per kWh of rated energy — you divide the total lifecycle CO₂e by the battery's rated energy in kWh. Numeric, to four decimal places. This is typically a value between 30 and 200 kg CO₂e/kWh depending on chemistry and manufacturing. For EV and Industrial passports, this is required for activation.

Lifecycle stages included

The lifecycle stages covered by your LCA. Select all that apply: Raw material acquisition and pre-processing, Main production, Distribution and transport, Use phase, End of life and recycling. Commission Regulation EU 2024/1257 requires at minimum: raw material acquisition, main production, and end of life.

Calculation methodology

The methodology reference. Pre-filled with "Commission Regulation EU 2024/1257 / JRC Battery Carbon Footprint Boundary methodology" — this is the correct value for most declarations. Only change it if your LCA was conducted under a different approved methodology.

Carbon footprint performance class

Your performance class as determined by your notified body — A, B, C, or D. Class A represents the lowest carbon footprint. The Commission defines class boundaries by delegated act.

Verification body

The name of the notified body that verified your declaration. For example: TÜV SÜD, SGS, Bureau Veritas, Intertek.

Verification certificate reference

The certificate number issued by the notified body. You will find this on the verification certificate document.

Declaration date

The date on which the declaration was issued (the date on the verification certificate).

Declaration document (optional)

You may upload the signed declaration document as a PDF. This is not mandatory — the structured fields above constitute the declaration. However, uploading the document provides an auditable record and may be requested by market surveillance authorities.

Per-lifecycle-stage breakdown (Article 7(1)(e))

Article 7(1)(e) and Annex II point 4 of the Battery Regulation require the carbon footprint to be differentiated by lifecycle stage. EU Digital Passport Processor™ provides four stage fields on the passport detail page, directly above the total intensity field:

Stage 2 primary data requirement: Your LCA consultant must use actual production energy data from your manufacturing facility for Stage 2. You cannot substitute secondary database values for Stage 2 if you are an EV or Industrial battery manufacturer. This is the most data-intensive part of the LCA — ensure your facility has energy metering in place before commissioning the study.

Stage 4 and the CFF: The Circular Footprint Formula allocates environmental credits and burdens between the battery producer and future recyclers. It is calculated by your LCA consultant and results in a value that may be negative (a net credit) if the battery contains significant recyclable metals.

Auto-sum feature: When you enter any stage values, EU Digital Passport Processor™ displays a running sum. Enter this sum in the total Declared Carbon Footprint field below the stage grid. The total must equal the sum of all stages included in your assessment — if you declare Stage 3 separately, include it in the total.

LMT batteries: All four stage fields show an amber Required from 18 Aug 2028 tag on LMT passports. You can enter stage data now if it is available from your LCA study.

Performance class A–D

The performance class ranks your battery's carbon footprint relative to EU-wide benchmarks defined in Annex II of the Battery Regulation. Class A represents the lowest carbon footprint.

Your notified body determines your class when they verify your declaration. The Commission publishes the boundary values for each class.